While I can't say that this will ultimately prove to be a class issue, the Fair Debt Collection Practices Act (“FDCPA”) is receiving increased attention in recent years, particularly as an increase in the number of consumers in economic distress increases their interactions with debt collectors. It is with this in mind that I pass on one sentence from a case involving the FDCPA. In Donohue v. Quick Collect, Inc., (9th Cir. January 14, 2009), the Ninth Circuit held: "We . . . conclude that a complaint served directly on a consumer to facilitate debt-collection efforts is a communication subject to the requirements of §§ 1692e and 1692f." Slip op., at 1006.

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The Complex Litigator reports on developments in related areas of class action and complex litigation. It is a resource for legal professionals to use as a tool for examining different viewpoints related to changing legal precedent. H. Scott Leviant is the editor-in-chief and primary author of The Complex Litigator.